Protection of Employees Reporting Employee Misconduct

Sarah Lawrence employees are expected to adhere to high standards of professional and ethical conduct in carrying out their duties.  Maintaining ethical standards, including appropriate accounting, internal controls, auditing and compliance with all federal, state and local laws is the responsibility of every member of the Sarah Lawrence community.  The College believes that early identification and resolution of ethical issues that may arise are critical to maintaining sound business, including but not limited to financial practices.

At Sarah Lawrence College responsibilities and decision-making are distributed throughout the organization. While we trust our employees to understand and abide by policies and the law, there may be rare instances of improper, even illegal activity.

Reporting Financially-Related Misconduct

Any employee who observes, first-hand, financial activities or other practices that he or she believes to be against the law or College policy should report these activities in the first instance to the Controller, located in Andrews Annex at X2556; the Controller will then review the case with the Vice President for Finance and Operations.  Alternatively, employees may submit concerns confidentially and anonymously regarding accounting, internal controls, auditing and other financial matters to John Hill, Chair of the Board of Trustees, c/o President's Office, or at jhill@firstreserve.com or (203) 625-2503.

Reporting of Non-Financial Misconduct

Report non-financial misconduct or misuse to the head of the appropriate office or department.  The department head will in turn provide a report of the complaint and its disposition to the Secretary of the College.

Reporting Misconduct by Those Individuals Responsible for Carrying Out This Policy

If the alleged improper or illegal behavior is by an individual responsible for carrying out this policy, then the incident should be reported as follows:  information regarding actions of the Controller should be reported directly to the Vice President for Finance and Operations; information regarding actions of the Vice President for Finance and Operations, the Secretary of the College or the head of any department of the College should be reported directly to the President; and information regarding actions of the President should be reported to the Vice President for Finance and Operations or the Secretary of the College, either of whom may consult with the Board of Trustees, or may be reported directly to the chair of the Audit Committee of the Board of Trustees.  Information regarding any of the College’s department heads should be reported directly to the President.

General

Whenever a case of possible improper or illegal behavior is reported, the person to whom it is reported shall prepare a written record of the complaint. A copy of the complaint will be shared with the Secretary of the College who will be responsible for receiving all such statements and investigating specific allegations.

Care will be taken to maintain appropriate confidentiality throughout the investigatory phase and for as long as possible. The results of any investigation will be reported to the Vice President for Finance and Operations and the President and, when necessary, to the chair of the Audit Committee of the Board of Trustees. The College will take appropriate action commensurate with the investigative findings.

The College will take steps to ensure that employees who come forward in good faith will be protected from retaliation in employment practices at Sarah Lawrence.  This protection is afforded to all employees who communicate information in good faith and through appropriate channels.

Approved by the Audit Committee of the Board of Trustees on 10/12/04